Sergej Suchanow sergej.suchanow@rsp-i.com In November 2023, we opened our youngest office in Tbilisi with the aim of supporting our clients in their business development. Georgia is located at the crossroads between Europe and Asia and its strategic location makes Georgia a natural logistics and transit hub along the Trans-Caspian trade route connecting Asia and Europe via the Caucasus. Georgia's economy is growing steadily. In 2021, growth amounted to 10.5 percent and in 2022 - 10.2 percent. Georgia has concluded free trade agreements with: 27 EU countries (Austria, Belgium, Bulgaria, Hungary, Germany, Greece, Denmark, Ireland, Spain, Italy, Cyprus, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Finland, France, Croatia, Czech Republic, Sweden and Estonia); 9 CIS countries (Russia, Belarus, Azerbaijan, Uzbekistan, Kazakhstan, Armenia, Kyrgyzstan, Moldova and Tajikistan); 4 countries of the European Free Trade Association (EFTA) (Norway, Iceland, Liechtenstein and Switzerland) Great Britain, Ukraine, China, Hong Kong, Turkey. There are currently 58 bilateral international agreements for avoiding double taxation, including with Germany and Austria. Georgia's banking system is connected to the European IBAN system. Georgia promotes so-called Tax Free Zones (TFZ) with special economic benefits. Full reliefs for TFZ residents include (mainland rates in brackets):: Corporate income tax (15% of the taxable profit base); Property tax (1% of the average book value of the property); Import tax (up to 18% of the import value); Value added tax (18%) Dividend tax (5%); Limited accounting in relation to employees' salary. In general, companies benefit from reliable infrastructure, low rental prices, ease of starting a business, low utility and communication costs and many other advantages. Financial support from the government enables the use of extended financing support mechanisms. #RSP #Georgia

Viktoriya Sleta viktoriya.sleta@rsp-i.com From 1st September entrepreneurs will not submit reports on land and property taxes. From 1 January 2024 a system of electronic reporting for small businesses and farms should be introduced in the tax authorities. A separate tax officer will be responsible for solving the problem of each entrepreneur in Uzbekistan. Specifically: Tax officers will work with micro-businesses with annual turnover not exceeding 1 billion soum in the mahallas and help them solve problems; with small businesses (turnover up to 10 billion soums) - heads of tax inspectorates of districts and their deputies; with medium business (up to 100 billion soums) - heads of tax departments of regions and their deputies; with large businesses (over 100 billion soums) - deputy chairmen of the Tax Committee. #Uzbekistan #Tax

Viktoriya Sleta viktoriya.sleta@rsp-i.com Payment of labour as reward in kind is possible with the written consent of the employee in the following cases: food products produced and grown by the employer, as well as other agricultural products - to employees involved in their production; in form of food and temporary accommodation - to workers hired to run a household. Payment of wages in kind must be stipulated in the employment contract. However, the total amount of wages in kind may not exceed 30%. The number of deductions provided for in Articles 269-270 of the Labour Code shall be taken into account. Irrespective of the employee's written consent, salary must not be paid as reward in kind if: an amount of up to 50 per cent is withheld - the total amount of wages paid to an employee in kind may not exceed 10 per cent; more than 50% of the salary is withheld. #Uzbekistan #Legal

Nikolai Knorr nikolai.knorr@rsp-i.com The Astana International Financial Centre (hereinafter referred to as “AIFC”) has been listed as a popular location for business in Kazakhstan for over three years. The Centre was established to modernise and develop the country, provide a more attractive business environment, attract investment flows, develop the securities market and provide companies with modern and efficient investment tools. It is a territory with a special legal regime in the financial sector established by the Constitutional Law of the Republic of Kazakhstan “On the Astana International Financial Centre”. It should be noted that all corporate procedures of legal entities registered with the Centre are governed by AIFC law. The applicable law of the AIFC is based on the Constitution of the Republic of Kazakhstan and consists of: the Constitutional Law; the acts of the AIFC not inconsistent with the Constitutional Law, which may be based on the principles, norms and precedents of the law of England and Wales and (or) the standards of the world's leading financial centers adopted by the AIFC bodies; the current law of the Republic of Kazakhstan, which applies to the extent not regulated by the Constitutional Law and the acts of the MFCA. In total, there have been adopted more than 70 acts of the AIFC to date. However, considering that the Centre is a new and developing institution, many procedural and practical issues still need to be finalized and regulated. In particular, AIFC did not regulate the procedure of voluntary winding-up of legal entities until recently. As a result, legal entities intending to terminate their activities voluntarily could not do that and many companies were left in a "frozen" state. In December 2021 there was successfully completed the first project on voluntary winding-up of a Private Company under the acts of Astana International Financial Centre. RSP International LLP acted as the Kazakhstani legal counsel of one of the private companies (further – „the Company“) in connection with all aspects of its voluntary liquidation. Within the framework of realization of this project, there was established a dialogue between AIFC, the tax authority and the state justice authority. Based on our own experience, in this article we will outline the basic procedural steps required for the voluntary winding-up of a Private Company under applicable AIFC legislation. Our notes are intended as a useful guide - they are not exhaustive and do not constitute legal advice. Voluntary winding-up under AIFC law is the independent liquidation of the Company approved by a simple majority of its members (shareholders). Such a decision is taken as soon as the Board of Directors of the Company decides that the Company has no reason to continue its operations. Voluntary liquidation can only be carried out if the Company is solvent, i.e. the assets of the Company must be sufficient to pay all debts in full, together with interest at the statutory rate, within a period not exceeding 12 months from the commencement of liquidation. In the case of voluntary winding-up, the Company must cease to operate from the commencement of the winding-up proceedings, unless the carrying on of the business may be required for its liquidation. However, the corporate legal personality and corporate powers of the Company shall continue until liquidation. As part of the preliminary stages of voluntary liquidation, the directors of the Company must make a formal Declaration of Solvency, which is expressed approved by a simple majority of the board of directors. The Declaration of Solvency must be made within 5 weeks immediately before the date of the liquidation resolution, or on the same day but before the resolution is approved. On the voluntary winding-up of the Company, there must be appointed one or more liquidators at a general meeting of members for the purpose of liquidating the Company and distributing its assets. The Liquidator appointed for the voluntary winding-up of the Company must necessarily be registered with the AIFC Register of Insolvency Practitioners and Official Liquidators. From the appointment of the Liquidator for the Company, all the powers of directors shall cease unless the Company in general meeting or the Liquidator approves their continuation. All tax requirements under the Company's voluntary liquidation procedure are fulfilled in accordance with the tax legislation of the Republic of Kazakhstan, as the tax regime in the territory of the International Financial Centre is determined by the Tax Code of the Republic of Kazakhstan, except for certain exemptions. The liquidation of the Company is considered completed when the company is dissolved after the final general meeting of the members conducted by the Liquidator. The voluntary liquidation procedure for a Private Company can last from 4 to 6 months. Once the liquidation process has been successfully completed, the legal entity ceases to exist. If during the voluntary liquidation procedure it transpires that the Company is not solvent, the Liquidator shall convene a meeting of creditors and the liquidation shall become a voluntary liquidation of the creditors. #Kazakhstan #Legal

Jörg Gulden joerg.gulden@rsp-i.com From January 1, 2022, the visa exemption for nationals from 54 countries, which was lifted due to the pandemic, will be back in force. The visa exemption applies, among others, to nationals of all EU countries, the UK and the USA for trips for tourist and business purposes with a stay of up to 30 days. However, the official entry permit is still required. This must be applied for by the inviting person and must be available before entry. This does not apply to nationals arriving by plane from countries with which regular air traffic has resumed, including Germany, Italy, Poland, the Czech Republic and the UK. #Kazakhstan #Legal

Joerg Gulden joerg.gulden@rsp-i.com After 18 months of construction that have been very interesting ones due to Covid, our new office in Tashkent is now open for business. We are very much looking forward to meeting you on our premises in RSP International 31 Taras Shevchenko Str 100060 Tashkent How to find us by Google Maps.

Patrick Pohlit patrick.pohlit@rsp-i.com The FNS has sent a new application letter to all tax authorities in order o ensure a uniform understanding of Article 54.1 of the RF Tax Code. The letter contains judicial and administrative practice and gives examples of willful acts by taxpayers in the context of misuse. In administrative practice, according to the companies, the local tax authorities apply the new Article 54.1 Tax Code RF in an inflationary manner as a sanction measure, especially with respect to the acceptnce of input VAT and operating expenses. The clarifications of the FNS in the letter of March 10th, 2021 N БВ-4-7 / 3060 @ lead to more transparency in enforcement practice both for companies and tax authorities, in particular when determining the actual amount of tax liability and liability for tax debts, which is intended to protect taxpayers in good faith. The letter also pays particular attention to the due diligence of taxpayers in the selection of contractual partners and suggests measures to be applied by the tax authorities in the context of a tax audit in order to identify the involvement of "technical" companies (bogus companies) in a transaction and to prove the deliberate use of such companies by taxpayers for the purpose of reducing the tax base. One of the main statements of the FNS is that Art. 54 Para. 1 Tax Code RF only applies in cases in which the examples of abusive structures proposed in the letter "cause damage to the tax authorities". It remains to be seen how the application letter will affect current tax authority practice. #Russia #Tax

Gabriela Ciacaru gabriela.ciacaru@rsp-i.com New Year - new rules. 2021 brings a lot of changes in the Romanian taxation systems. You will find a detailed description in this document. #Romania #Tax

The COVID-19 pandemic was the biggest external shock to the economy since the independency of the country. The impact on economic growth is expected to a result in a growth rate of - 3 % in 2020 Other than the oil price shocks of 2009 and 2015, the pandemic has not only affected demand but also the supply side of the economy through a couple of lockdowns. Lockdowns, albeit necessary to contain the pandemic, are especially disruptive for businesses that are reliant on physical customer contact. The Kazakh government acted very quickly to the threats of the pandemic with the proclamation of a state of emergency and various measures to contain the spread of the virus and assist businesses and individuals that have been affected by those measures, especially through a generous fiscal package. However the final impact of the fiscal and monetary stimuli will largely depend on the further development of the pandemic. A long lasting series of further lockdowns into the first half of the next year will bear hte risk of a long lasting slowdown in economic growth. Traditionally the global economic situation has a high impact on the Kazakh economy with the stioll high dependency on demand for natural ressources. Economic Outlook Current projections see a contraction of the GDP by 3 percent in 2020 and a recovery of around 4 percent in 2021. Inflation pressure is expected to remain but will slow as the effect of exchange rate depreciation gradually fades away. Inflation this year will remain above the central bank target of 6 percent, following depreciation of the tenge. With respect to foreign investement, we expect an even more positive development in 2021. A siginifcant number of our clients have signed contracts for construction and assembly projects that have been delayed or halted mainly by the travel restrictions for foreign specialists. With vaccination available, we expect most of them to start entering realisation phase in the first quarter of 2021. Provided that economic and fiscal stimuli will be prolonged, the rebouncing demand will lead to further option for projects and local direct investments. Once the global economy will start to recover. RSP in Kazakhstan We at RSP are still very positive with respect to mid-term and long-term development. Showing our committment, we have - despite the numerous obstacles - finalised the construction of our own office premises and have already moved in. We are looking forward to seeing you there, at Samal 2, bldg. 33A, 21. floor 050051 Almaty. The opening party is postponed not forgotten!

Zurab Tsereteli zurab.tsereteli@rsp-i.com In accordance with the decree of the Mayor of Moscow No. 97-UM dated 06.10.2020, Moscow employers need to report to the Сity administration about employees (including performers under civil law contracts) who are and are not subject to remote work. The employees subject to transfer to remote work have to provide the following information to the employer: mobile phone number; state registration number of the vehicle (if any); number of the Troika electronic card (if any); number of the Strelka electronic card (if available); number of the social card issued based on decisions of the executive authorities of the city of Moscow and the Moscow region (organizations authorized by them) (if any); number of a monthly travel ticket without travel limit and with a limit of 70 travel, temporary unified social ticket, temporary discount ticket (if any). The report must be submitted in the prescribed form weekly each Monday, starting 12.10.2020, in electronic form using the legal entity's personal account on the official website of the Moscow Mayor https://ulk.mos.ru/. The service for submitting the report is available via the personal account of organizations from 09.10.2020 on. The report can be downloaded from this date. Nevertheless, we recommend you register your organization's personal account on the website https://ulk.mos.ru/ and receive information from your employees in advance. Please note that violation of the requirements of the decree leads to imposition of administrative sanctions on both, the organization and its officials (Article 20.6.1 of the Code of Administrative Offences of the Russian Federation). According to this regulation, failure to submit a report or submission of false information shall result in a fine: for officials of the organization - in the amount of 10 thousand to 50 thousand rubles, for a legal entity - in the amount of 100 thousand to 300 thousand rubles Repeated failure to submit a report or submission of incorrect information shall result in a fine for officials - from 300 thousand to 500 thousand rubles or disqualification for a period of 1 to 3 years; for legal entities - from 500 thousand to 1 million rubles or administrative suspension of activities for up to 90 day The Decree No. 97-UM dated 06.10.2020 and the report form can be found here. #Russia #Legal

Joerg Gulden joerg.gulden@rsp-i.com Germany will introduce an extensive package of measures to support the economy according to a plan published by the Ministry of Finance on Wednesday, June 3rd, 2020. The package contains 57 individual measures to stimulate the economy immediately and in the medium term. The following aspects are particularly important for companies from a tax and legal perspective: VAT reduction: Standard VAT rate from 19% to 16% and the reduced tax rate from 7% to 5% for the period from 1st of July until end of December 2020 Limitation of social security contributions to a maximum of 40% Surcharge on electric energy will be reduced to to 6.5 ct / kwh in 2021 and 6.0 ct / kwh in 2022 from currently 6.756 ct / kwh Due date for import VAT will be postponed to the 26th of the following month For the years 2020 and 2021, the maximum permissible tax loss carry-back will be increased to a maximum of EUR 5 million and EUR 10 million (in the case of a joint assessment of individuals). The utilisation of losses shall already be usable in FY 2019 with details to follow (Re-)introduction of degressive depreciation method for fiscal purposes with a factor of 2.5 and a maximum of 25% per year for movable assets, limted to FY 2020 and 2021 Changes in corporate tax law: especially an model to opt for corporation tax instead of personal income tax for partnerships and reductions for commercial tax Changes in bankruptcy law, in particular introduction of a pre-bankruptcy restructuring process Additional promotion of employee participation models Financial aid or SMEs depending on the drop in sales caused by Covid-19 - up to 50% or 80% of the fixed operating costs Raising the maximum assessment base for the research allowance to EUR 4 million Further industry-specific measures and all other planned regulations and investment programs can be found on the website of the Ministry of Finance (German languange). #Germany #Tax #Legal #Covid1

On April 1, 2020, the federal law “On Amending Certain Legislative Acts of the Russian Federation on the Prevention and Response of Emergencies” of March 31, 2020 came into force, hereinafter the Federal Law. Article 19 of the Federal Law establishes a number of privileges for tenants of real estate with respect to lease contracts of real estate concluded before the introduction of the high alert in the relevant region. Part one of Art. 19 of the Federal Law obliges the landlord to conclude an additional agreement within 30 days from the day the tenant appeals, providing for a deferment of payment of the rent stipulated in 2020. Requirements for the conditions and terms of such a delay are established by the Government of the Russian Federation. As of the date of preparation of this newsflash, the corresponding act has not yet been adopted by the Government of the Russian Federation. Part two of aforementioned article provides for the possibility of changing the amount of rent by agreement of the parties at any time during 2020. Finally, the third part of Article 19 allows the tenants to demand a reduction in rent for the corresponding period of 2020 due to the inability to use property associated with the adoption by the state authority of the subject of the Russian decision on the introduction of a high alert or emergency on the territory of the subject of the Russian Federation. The high alert mode in certain regions was introduced at different times, for example, on March 5, 2020 in Moscow, March 13, 2020 in St. Petersburg. Since March 19, the high alert mode has been operating in all regions of the Russian Federation. We will be happy to give further advice on this matter, as well as help prepare the appropriate appeals to landlords. #Russia #Legal #Covid19